For CIP, do we need to keep actual copies of documentation used to identify a business (for example, Articles of Incorporation)?
Regarding the TIN requirement of BSA 31 CFR 130.34, does it apply to the members of religious groups who do not have SSNs or TINs due to their beliefs? If they want to open an account, are they required to furnish a TIN? What if they don't have a TIN and they are an existing customer?
Under the USA PATRIOT Act regulations and upcoming CIP, do we need to have photocopies of the driver's license and/or social security numbers for beneficiaries on a Totten Trust? In most cases, we never see the beneficiaries, as they are not signers on the account. Also, do we have to check them on OFAC?
I am reviewing the final reg for the CIP and making adjustments to the program and procedure we compiled several months ago. At the end of the discussion of Section 103.121(b)(2)(iii) for Lack of Verification, the final reg indicates "...a bank must comply with other applicable laws and regulations, such as the adverse action provisions under ECOA and FCRA, when determining not to open an account because it cannot establish a reasonable belief that it knows the true identity of the customer." ECOA and FCRA deal with credit products, and I do not see how the current notices apply to denial because you cannot establish someone's identity. Even if you mark "Other" the notice portion refers to credit and I believe it would confuse the applicant. Any thoughts on this?
With regard to the new CIP regulations, will we have to include indirect auto loans in the ID verification process, or can we rely on the info furnished on the application to the original creditor? (aka the auto dealer.)
Is there a specific size requirement for the USA PATRIOT Act CIP customer notice sign?
Does a corporate fiduciary (trust Dept) need any form of ID under CIP for testamentary trusts that they are opening as trustee. example: Jane Smith dies leaving a will and names the bank as trustee of the trust for the benefit of her grandchildren.
When opening an account for a new customer must the individual present his or her social security card or provide documentation to verify the SS#, as a result of the provisions of the USA PATRIOT Act? Is not providing the SS# along with proper ID enough? Many individuals don't have anything with the SS# on it or carry it with them. We don't want to turn prospective account holders away for not having their SS Card.